Are we allowed under TRID to add a release fee to a consumer mortgage payoff? The fee would be for recording the satisfaction of mortgage.
This question was asked and answered back in April 2012, but I was wondering if there had been a final proposal to answer this question? If our institution waits the 45 days required after both notices regarding a borrower's lapse in hazard insurance are sent, and then force placed, can we back date the policy so that it is in effect the day of cancellation and still be in compliance with the Dodd-Frank Act? The second part is this: if this is not in compliance, how can we structure force placement of the insurance, and the notices required, so as to be in compliance, and still make sure the home is covered? Basically, would our institution have to foot the bill for that 45 days?
Can you tell me what fees are supposed to affect the APR?
An Appraisal Management Company, (AMC) is increasingly charging an additional fee of $150 and attributing its justification to the CFPB's Rural or Underserved provisions. My understanding and research does not support the AMC's claim allowing this added fee. I have spoken to others in the business and they have no experiences with such a fee, short of USDA-RD fees. Is this particular AMC correct in how it is treating these properties while citing the CFPB?
If a loan has a privately held mortgage, is that HMDA reportable?